Subject: File Number 4-573

October 31, 2008

Will summaries of the roundtable discussions on FAS 157 be available publicly?

As a pension actuary whose clients will be negatively impacted by FAS 157 I want to keep up with the SEC's thinking on this matter. I believe that FAS 157 had a very significant role in the recent market turmoil by creating an irrational negative feedback loop. Congress created a significant mess but it took a recent change in accounting rules to distort the problem beyond all recognition.

Just 1 example sort of crystallizes this for me: says "Merrill Lynch & Co. ... sold more than $30 billion in toxic mortgage-related assets at just 22 cents a dollar." You have to estimate that the true value of these assets was probably significantly higher since the buyer is known to be very savvy (and was one of the few funds with the stomach for the risk and work involved).
Tom Schryer, A.S.A.